Organic handlers, processors, manufacturers and other key players in the organic industry supply chain often have the same general questions about organic product management.
If you have a very specific question about your company's organic supply management, know that it's always best to check with your personal organic certifying agent.
1. Do Organic Handlers Need to be Certified Organic?
All organic handlers who handle operations, or portions of operations, that produce or handle agricultural products that are going to be labeled and sold as "100 percent organic," "organic," or "made with organic ingredients" must be certified by the USDA National Organic Program (NOP).
Handlers who sell less than $5,000 a year in organic agricultural products are not required to be officially certified, but they still must abide by organic policy in order to label products as organic.
2. Do You Have to be Certified Organic to Handle Packaged Organic Goods?
Handlers who handle organic pre-packaged organic products do not need to be certified organic. For example, a handler may acts as a go-between for an organic packer and retailer, getting bagged carrots from farm to store. This type of handler, who handles only pre-packaged carrots, wouldn't have to be certified.
Organic product must remain packaged if handled by a non-certified party. Handlers must also prevent the product from coming into contact with prohibited substances under the NOP National List.
3. What is the National List?
Often, organic certifying agents, the USDA and other organic industry players will mention, "The National List." This is simply a short way of saying, "The National List of Allowed and Prohibited Substances."
The National List of Allowed and Prohibited Substances, established by the Secretary of Agriculture, is a list of allowed and prohibited substances that can and cannot be used in organic products and organic production and handling operations. The list includes both nonsynthetic and synthetic substances.
4. How Long Should I Keep Organic Records?
Handlers applying for certification are required to keep accurate organic handling records for 5 years post-certification. Records must include information about production, harvesting, and all aspects of handling of agricultural products sold as organic. Furthermore, organic handlers must allow any authorized representatives of the USDA, along with organic certifying agents, to see the records if asked.
5. Can Organic Products and Non-Organic Products be Processed Together?Handlers who are certified to manage organic products may also handle non-organic products in the same facility. A facility does not have to be entirely dedicated to organics. Sections of the facility do need to be dedicated organic though. For example, special measures must be used to prevent co-mingling of prohibited product materials and cleaning solutions with organics.
6. Do Off-Site Storage Facilities Need to be Certified OrganicOff-site storage facilities, distribution centers and other organic product storage facilities do not need to be certified organic, so long as organic products are completely enclosed with packaging. Organic product containers may not be opened and repackaged at an off-site, non-certified facility.
7. Can Organic and Conventional Produce be Displayed Together?
Conventional produce can be displayed above, below, or close to organic produce. There are zero specific requirement regarding exact placement of organic produce in relation to conventional. However, NOP does state that, "There must be sufficient measures taken (packaging, distance, physical barriers) to prevent commingling and contamination between organic and conventional produce."
8. If a Label Says "Made With Organic Ingredients" is Certification Required?
If you process or handle a food product that is labeled with the term, "Made With Organic Ingredients” then the product must be certified organic. Without USDA organic certification, food products cannot claim any sort of organic relationship.
Organic body care and personal care products are another story. Organic claims about personal care products aren't currently regulated unless the product is officially certified organic.
9. Can I List Organic Ingredients on the Ingredient Statement?
A cookie product may list the following ingredients: flour, milk, organic eggs, chocolate chips, vanilla and so on. Although the cookies contain organic eggs, the cookies themselves do not need to be certified organic.
Food products are allowed to use organic claims in the ingredient statement section, so long as a product doesn't use organic claims elsewhere on the label. For example, just because you used organic eggs, you can't plaster, "Made With Organic Ingredients" or "Organic Cookies" on the front of the cookie package.
That said, manufacturers are required to maintain organic documentation on all listed organic ingredients and the ingredients must meet NOP standards for organic.
10. What Cleaners and Pest Controls Can be Used in a Certified Organic Facility?
A certified organic facility, or a facility that handles organic products partially must adhere to strict cleaning and pest control methods. The “Generic Materials and Brand Name Products Lists” from the Organic Materials Review Institute and the National List, discuss cleaners and pest controls that can and cannot be used around organic products.
In general, organic products must not be exposed to forbidden substances and you should clean with organic cleaning products that meet NOP organic requirements. Before creating a facility cleaning plan make sure your plan suits both NOP regulations and local health and safety codes.